> ZOrsnaw Zorsama w Supreme Courtof Pennsylvania y Court o£ CommomPleas For Prothonotary Use Only: ; Cixil Cover Sheet Docket No Bl Bog County 802S-11 01 £3 The information collected on this form is used solely for court administration purposes. This form ddes not supplement or replace the filing and service of pleadings or other papers as required by law or rules of ob. ‘Commencement of Action: Bl Complaint 1 weit of summons O Petition : DD Transfer from Another Jurisdiction 1 Declaration of Taking ov Aremoney damages requested? ves ChNe | Miramonte Is this a Class Action Suit? Dyes EINo Is this an MDJ Appeal? = 1] Yes. El No ‘Name of Plintf/Appllant’s Atomey: Shanin Specter, Esq. and Conor Lamb, E59. 1 Cheek here ityou have no attorney (are a Self Represented (Pro Se] Litigant) Nature of the Case: Place an “X” to the left of the ONE case category thet most accurately describes your PRIMARY CASE, If you ate making more than one type of claim, check the one that you consider most important TORT (do nor nclude Mass Tort) CONTRACT (oo inciule Judges) | | CIVIL APPEALS. D1 intentional D1 Buyer Plaintist ‘Administrative Agencies Malicious Prosecution 1 Debt Collection: Credit Card 1 Board of Assessment Motor Vehicle Bi Debt Collection: Other Board of Elections EI Nuisance Dept, of Transportation Premises Liability Statutory Appeal: Other DD Product Liability (does not include C1 Employment Dispute: mass tort) OA rae Diserimination ae [Employment Dispute: Other 1 Zoning Board False imprisonment, sexual — D other: Dotter: MASS TORT DD Asbestos Ei Tobacco EF Toxic Tort - DES DF Toxie Tort- Implant REAL PROPERTY MISCELLANEOUS Toxie Ws Ey] Toxic Waste Di Electment 1D Common Law/Statutory Arbitration E Other: Eminent Domain/Condemnation 1 Declaratory Judgment Ground Rent Mandamus EF Landtord/Tenane Dispute Non-Domestic Relations [5 Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY Bi Mortgage Foreclosure: Commercial Quo Warranto 1 Dental Ey Panition Di Replevin D Legal i Quiet Title D other: 1 Metical Blotter: _ 1 Other Professional: Updated 1/1/2011NOTICE Pennsylvania Rule of Civil Procedure 205.5. (Cover Sheet) provides, in part: Rule 208.5. Cover Sheet (@)(1) This rule shall apply to all actions governed by the rules of civil procedure except the following: (actions pursuant to the Protection from Abuse Act, Rules 1901 et seq. wi actions for support, Rules 1910.1 et seq. actions for custody, partial custody and visitation of minor children, Rules 1915.1 et seq (iv) actions for divorce or annulment of marriage, Rules 1920.1 et seq, (v) actions in domestic relations generally, including paternity actions, Rules 1930.1 et seq, (vi) voluntary mediation in custody actions, Rules 1940.1 et seq. 2) At the commencement of any action, the party initiating the action shall complete the cover sheet set forth in subdivision (e) and file it with the prothonotary. (b) The prothonotary shall not accept a filing commencing an action without a completed cover sheet. (©) The prothonotary shall assist a party appearing pro se in the completion of the form, @ A judicial district which has implemented an electronic filing system pursuant to Rule 205.4 and has promulgated those procedures pursuant to Rule 239.9 shall be exempt from the provisions of this rule, (e) The Court Administrator of Pennsylvania, in conjunction with the (Giyil Procedural! shall design and publish the cover sheet, ‘The latest version of the form shal be published on the website of the Administrative Office of Pennsylvania Courts at www.pacoutts.us, Rules CommitteKLINE & SPECTER, Ps BY: — Shanin Specter, PA ID# 40928 Conor Lamb, PA ID# 304874 1525 Locust Street, Nineteenth Floor Attorneys for Plaintiff : : Philadelphia, PA 19102 i 3 shanin.specter(@klinespecter.com : conor.lamb@klinespecter.com (215) 772-1000 a IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY, PENNSYLVANIA “OR cM, CIVIL DIVISION Plaintiff No: 2OAS-\\loT KURT RILLEMA, COMPLAINT IN CIVIL ACTION Defendant. JURY TRIAL DEMANDED ‘You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attomey and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff, You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE ALAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO. PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFERLEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Centre County Court Administrator's Office 102 South Allegheny Street Bellefonte, PA 16823, (814) 355-6727 KLINE & SPECTER, P.C. Conor Lamb SHANIN SPECTER, ESQUIRE CONOR LAMB, ESQUIRE Attorneys for Plaintiff BY: Date: May 24, 2023KLINE & SPECTER, P.C. BY: — Shanin Specter, PA ID# 40928 ‘Conor Lamb, PA ID# 304874 1525 Locust Street, Nineteenth Floor Philadelphia, PA 19102 shanin,specter@klinespecter.com conor.lamb@klinespecter.com ° : (215) 772-1000 oe Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY, PENNSYLVANIA CM. CIVIL DIVISION peta) NO: QOdBUWT . KURT RILLEMA, COMPLAINT IN CIVIL ACTION Defendant. JURY TRIAL DEMANDED CIVIL ACTION COMPLAINT AND JURY DEMAND 1, Plaintiff is a resident of Montgomery County, Pennsylvania, She is a victim of rape, and her identity is not pleaded in this Complaint in order to avoid further notoriety and psychological harm. Plaintif’s identity will be made known to the Defendant by separate communications and shall be kept confidential. Plaintiff is 42 years old. 2, Defendant is a resident of Oakland County, Michigan, with an address at 3204 Interlaken Street, West Bloomfield, Michigan 48323, He has been engaged in various businesses, including as a managing member of Eagle Contracting, LLC, a national mechanical contractor for HVAC systems. Defendant is 51 years old. 3. Venue is properly laid in Centre County, Pennsylvania, pursuant to Pa.R.C.P, 1006 and 2156, as Defendant committed the false imprisonment, sexual assault and physical battery,and intentional infliction of emotional distress described below upon Plaintiff while he was visiting Centre County, and she was present in Centre County as a student at Pennsylvania State University. OPERATIVE FACTS 4. On the evening of July 27, 2000, Plaintiff was a student at Pennsylvania State University, and she was running for recreation on the Blue Golf Course at 1523 West College Avenue, State College, Pennsylvania, At the time, Plaintiff was 19 years old. 5. At approximately 8:15 p.m., Plaintiff encountered Defendant near the 17" hole of the golf course. 6. Plaintiff passed by Defendant, but soon noticed him running parallel to her near the 18" hole of the golf course. 7. Defendant approached Plaintiff from behind and brandished a knife, which he held to Plaintiff's throat. 8. Plaintiff did not recognize Defendant. He was a complete stranger to her. 9. Defendant told Plaintiff she would not be harmed if she stayed quiet. 10. Plaintiff began crying, and Defendant hit her in the stomach. 11. Defendant forced Plaintiff to enter a wooded area near the 18" hole of the golf course, 12, Defendant then forcibly raped Plaintiff by performing sexual intercourse upon her. Atno time did Plaintiff consent to sexual intercourse with Defendant. 13, After Defendant was finished raping Plaintiff, he told her not to move, and that he ‘would harm her if she told anyone, Defendant then fled the wooded area, 14, After Defendant left the scene, Plaintiff made her way to the golf course’s pro shop, where a staff member alerted police at approximately 8:31 p.m.15, Plaintiff made a full report of the rape to police on the same night that it occurred, but Plaintiff did not know Defendant's identity. She provided the best physical description of her assailant that she was able, 16. Plaintiff was transported the same night to Mount Nittany Medical Center, where a sexual assault kit, including physical and biological evidence, was collected. 17. OnJuly 31,2000, officers of the Penn State Police Department (“PSPD”) submitted Plaintiff's sexual assault kit to the Pennsylvania State Police Bureau of Forensic Services, Harrisburg Regional Laboratory. 18. In October 2000, the Harrisburg Regional Laboratory reported that sperm was identified in the pieces of Plaintiff's underwear and the vaginal swabs collected as part of the sexual assault kit. 19. Also in October 2000, an officer of the Penn State Police Department (“PSPD”) submitted the pieces of Plaintiff's underwear and the vaginal swabs collected as part of the sexual assault kit, as well as samples of Plaintiff's blood, to the Pennsylvania State Police DNA Laboratory (“DNA Lab”) in Greensburg, Pennsylvania. 20. Asthe investigation continued, Plaintiff continued to cooperate with the PSPD. She visited the golf course with them and participated in a lineup of potential suspects. 21. On January 4, 2001, the PSPD received the results of the DNA Lab's analysis, which concluded that a DNA profile foreign to Plaintiff was present in what the Lab referred to as the “sperm fraction” of the pieces of Plaintif’s underwear and vaginal swabs. 22, The PSPD entered the foreign DNA profile into law enforcement databases, but found no match. As a result, Defendant remained unidentified as the perpetrator of the rape of Plaintiff,23. On August 2, 2004, the PSPD was notified by the DNA Lab that the foreign DNA profile identified in the “sperm fraction” of the pieces of Plaintiff's underwear and her vaginal swabs matched a profile identified in a similar rape case in Michigan, which occurred at Twin Lakes Golf Course in Oakland County in 1999. The perpetrator of the Michigan rape was also unidentified. 24, In June 2011, the PSPD preserved the criminal statute of limitations by filing a “John Doe” criminal complaint in Centre County which described the genetie profile of the person whose DNA was found in the evidence collected from Plaintiff, The PSPD contacted Plaintiff before filing this complaint and she expressed her approval of continuing to pursue the investigation and prosecution, including by filing the John Doe complaint. 25. It has become more common in recent years for law enforcement agencies to attempt to solve so-called “cold cases” by submitting crime-scene DNA profiles to entities that compare them with DNA profiles obtained from online consumer databases, which often contain DNA profiles of people who voluntarily submitted a DNA sample for the purpose of genealogical research, 26. Parabon Nanolabs is one such entity that attempts to solve cold cases through what they call “genetic genealogy.” Parabon’s website defines genetic genealogy as “the combination of genetic analysis with traditional historical and genealogical research to study family history.” Parabon’s website further explains that “[b]y comparing a DNA sample to a database of DNA from volunteer participants, it is possible to determine whether there are any relatives of the DNA sample in the database and how closely related they are.” 27. Detective Nick Sproveri of the PSPD visited Plai ‘at her home in late summer or early fall 2021 to discuss the process of submitting the DNA profile from her case to ParabonAs she did in 2011, Plaintiff expressed her approval of continuing to pursue the investigation and prosecution, including by submitting the DNA profile to Parabon, 28. In January 2022, Detective Sergeant Eric Tremonti of the Oakland County (Michigan) Sheriff's Office submitted evidence containing semen from the 1999 Michigan rape to Arbor Biosciences, a private lab in Ann Arbor, Michigan, that works with Parabon to perform genetic genealogy analysis. 29. On January 17, 2023, Detective Sergeant Tremonti and Detective Sproveri of the PSPD each received a genetic genealogy report from Parabon, which concluded that the DNA profile of the perpetrator of the 1999 Michigan rape belonged to one of three brothers: Defendant, Bradley Job Rillema, or Mare Joseph Rillema, 30. Detective Sergeant Tremonti and Detective Sproveri determined that Defendant ‘was the perpetrator of the 1999 Michigan rape, and the rape of Plaintiff, based upon his physical in Lakes Golf Course at makeup compared with the victims’ descriptions, his residence near T\ the time of the 1999 Michigan rape, and the fact that his brother Mare was a Penn State student at the time of the rape of Plaintiff. ‘The detectives concluded that Defendant was likely visiting his brother at Penn State on the day that he raped Plaintiff. 31. On January 31, 2023, officers of the Oakland County (Michigan) Sherriff's Office performed surveillance on Defendant, with the goal of obtaining a sample of his DNA. The surveillance officers saw Defendant drink coffee from a Styrofoam cup. When he later discarded the same cup, the surveillance officers took it, and Detective Sergeant Tremonti submitted it to the Michigan State Police Forensic Laboratory (“MSPFL") for testing.32. On March 20, 2023, the MSPFL reported that it had developed a DNA profile from the Styrofoam cup which was sufficient for comparison purposes. The DNA profile was tested against the DNA profile from the semen found in the 1999 Michigan rape case, and it matched. 33. According to the Michigan State Police Forensic Laboratory, the probability of the matching DNA profiles being anyone other than Defendant is I in 510 sextillion. 34. As noted above, the DNA profile of the semen from the 1999 Michigan rape case had previously matched the DNA profile obtained from the sperm fraction of the pieces of Plaintiff's underwear and the vaginal swabs collected as part of the sexual assault kit in Plaintif’s case. 35. Plaintiff first learned Defendant's name in March 2023. 36. On April 3, 2023, President Judge Jonathan Grine of the Centre County Court of Common Pleas issued a warrant for Defendant’s arrest, based on the evidence that he raped Plaintiff on July 27, 2000, as described above. 37. Defendant is currently in custody in Michigan, facing charges there for the 199 Michigan rape. The Commonwealth of Pennsylvania has filed a detainer and plans to prosecute Defendant criminally in Pennsylvania for the rape of Plaintiff, 38. Plaintiff did not know, and in the exercise of reasonable diligence could not have known, Defendant’s name or identity before May 24, 2021. 39. The outrageous conduct of Defendant was a factual cause of Plaintiff's harm and ‘was a substantial factor in cau ng and did directly proximately cause harm to Plaintiff, including a, Sexual assault; b. Unwanted sexual contact; c. Mental anguish, humiliation, pain, suffering, and emotional trauma from having unwanted sexual contact;4. Depression; fe. Anxiety; f. Nightmares; . Fear; h. Flashbacks; Panic attacks; Racing thoughts; k. Costs associated with mental health treatment; 1. Intense psychological distress; m, Past and future economic loss; n, Past and future embarrassment and humiliation; ©. Past and future pain and suffering, mental anguish and loss of life’s pleasures; . Other physical, economic, and psychological injuries, some of which may be permanent, arising of the inappropriate sexual contact. 40. Plaintiff's injuries were caused solely by Defendants outrageous conduct, and were not caused or contributed thereto by any negligence on the part of the Plaintiff. COUNT ONE - FALSE IMPRISONMENT. 41, The preceding paragraphs of this Complaint are incorporated as though fully set forth herein, 42. On the evening of July 27, 2000, Plaintiff had a legal right to be present on and/or near Penn State’s Blue Golf Course,43, On July 27, 2000, while Plaintiff was lawfully running for recreation on Penn State's Blue Golf Course, Defendant detained her and forced her to enter and remain in the wooded area, as described above. 44, Defendant's detention of Plaintiff was unlawfil 45. Asa direct and proximate result of Defendant’s unlawful detention of her, Plaintiff has suffered and continues to suffer physical, mental, and emotional harm as described above. 46, Defendant’s actions were done willfully, maliciously, and with wanton disregard for Plaintifi’s safety and well-being. As a result, Plaintiff is entitled to an award of punitive damages. COUNT TWO - ASSAULT AND BATTERY 47. The preceding paragraphs of this Complaint are incorporated as though fully set 48, The conduct described above, committed by Defendant against Plaintiff on July 27, 2000, constitutes sexual assault and physical battery. 49, Asa direct and proximate result of Defendant's sexual assault and physical battery, Plaintiff has suffered and continues to suffer physical, mental, and emotional harm as described above. 50. Defendant's actions were done willfully, maliciously, and with wanton disregard for Plaintiff's safety and well-being. As a result, Plaintiff is entitled to an award of punitive damages. COUNT THREE — INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS 51. The preceding paragraphs of this Complaint are incorporated as though fully set forth herein,52. Defendant’s false imprisonment, assault, and battery of Plaintiff on July 27, 2000 constitute extreme and outrageous conduct. 53. Defendant’s extreme and outrageous conduct was reckless, in that he knew that Plaintiff's severe emotional distress was certain, or substantially certain, to result, and/or he deliberately disregarded a high degree of probability that Plaintiff's severe emotional distress would follow Defendant's conduct. 54. Defendant’s reckless, extreme, and outrageous conduct, done with wanton, conscious distegard for Plaintiff's welfare, caused Plaintiff to experience severe emotional distress, as described above. 55. Asa result of the reckless, extreme, and outrageous conduct of Defendant as set forth in this Complaint, Plaintiff suffered and will continue to suffer physical manifestations of severe emotional distress, including anxiety, depression, fatigue, insomnia, nausea, and other symptoms for which, under the law, she is entitled to recover compensatory and punitive damages.WHEREFORE, Plaintiff respectfully demands compensatory and punitive damages against Defendant in an amount in excess of the local arbitration limits, exclusive of interest, costs, and damages for prejudgment delay. Dated: May 24, 2023 By: Respectfully submitted, KLINE & SPECTER, P.C. Conor Lamb SHANIN SPECTER, ESQUIRE PA Attorney LD. No, 40928 CONOR LAMB, ESQUIRE PA Attorney I.D. No. 304874 1525 Locust Street, 19" Floor Philadelphia, PA 19102 Telephone: (215) 772-1000 Facsimile: (215) 402-2359 Shanin.Specter@klinespecter.com Conor,Lamb@klinespecter.com Attorneys for Plaintiff 10Vinesign Document ID: F41CCFA3-8C7D-4DA5-93DA-9949497F95AF VERIFICATION 1, C.M. hereby state that I am the Plaintiff in the within matter, and as such verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. ‘The undersigned understands that the statements herein are made subject to the penalties of 18 Pa, CS, 4904 relating to unsworn falsification to authorities. Date: May 24, 2023 MW CM. The signed document can be validated at https://app.vinesign.com/VerifyKLINE & SPECTER, P.C. BY: — Shanin Specter, PA ID# 40928 Conor Lamb, PA ID# 304874 1525 Locust Street, Nineteenth Floor Attorneys for Plaintiff Philadelphia, PA 19102 shanin.specter(@klinespecter.com conor.lamb@klinespecter.com (215) 772-1000 IN THE COURT OF COMMON PLEAS OF CENTRE COUNTY, PENNSYLVANIA CM., CIVIL DIVISION Plaintiff, No: 2OAS-|\loT . KURT RILLEMA, COMPLAINT IN CIVIL ACTION Defendant. JURY TRIAL DEMANDED PUBLIC ACCES OLICY CERTIFICATION, that this filing complies with the provisions of the Case Records Public Access Policy of the Unified Judicial System of Pennsylvania that require filing confidential information and documents differently than non-confidential information and documents, KLINE & SPECTER, P.C. Conor Lamb SHANIN SPECTER, ESQUIRE CONOR LAMB, ESQUIRE BY: Attorneys for Plaintiff Date: May 24, 2023